ML20063H574
| ML20063H574 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/27/1982 |
| From: | Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8207300326 | |
| Download: ML20063H574 (4) | |
Text
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, h, UNITED STATES OF AMERICA 00CKETED NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECRET
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- 00CKETI:4G & SERVICE d
' BRANCH In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322 0.L.,
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(Shoreham Nuclear Power Station,
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Unit 1)
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SUFFOLK COUNTY MOTION TO STRIKE PORTIONS OF LILCO PREFILED TESTIMONY ON SC CONTENTION 16 -- ANTICIPATED TRANSIENTS WITHOUT SCRAM Suffolk County moves to strike Questions and Answers 10 (except the last paragraph) "and 21 from the LILCO prefiled testimony on SC Contention 16 - ATWS.
The basis for this motion is that these portions of the testimony are not relevan't to SC Contention 16 as framed by the Board.
SC Contention 16 concerns whether the Shoreham systems, procedures and. training for dealing with an ATWS event are adequate and whether there is compliance with GDC 20 despite the fact that the Shoreham Standby Liquid Control System is not automatic.
The Contention makes the assumption that an ATWS event will occur and then questions the adequacy of methods to mitigate the consequences of an ATWS event.
Thus, the focus
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of SC Contention 16 is on mitigation of an ATWS event.
The portions of the LILCO testimony which the County seeks to strike do not concern mitigation of an ATWS event.
- Rather, these portions, in effect, argue tha,t an ATWS event will not occur.
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Thus,- Question and Answer 10 (except for the last paragraph) provides a description of the Shoreham scram system, with the focus being on the fact that it allege'dly is highly unlikely to fail.
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SiMilarly, QuestioH and Answ6r~21 address the witnesses' view
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that a severe ATWS event is unlikely during the interim period
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referenced in the Contention.-
Suffolk County believes that suffolk County Contention 16, as reworded by the Board on March 10, 1982, focuses only on the adequacy of LILCO's means to mitigate the effects of an ATWS event.
The Contention does not concern whether an iTN5~e' vent will in fact occur, as that is a "given" in the context of this Contention.
Thus, the cited portions of the LILCO testimony are outside the scope of the Contention and should be struck.
Respectfully submitted, David H. Gilmartin Patricia A.
Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 OE a
Herbert H.
Brown '
Lawrence Coe Lanpher Karla J. Letsche KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.
Washington, D.C.
20036 (202) 452-7000' July 27, 1982 Attorneys for Suffolk County
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Evidence concerning the probability of successful mitigation of an ATWS event would be relevant in the County's view.
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UNITED STATES OF AMERICA SHRC NUCLEAR REGULATORY COMMISSION "h
i BEFORE THE ATOMIC SAFETY AND LICENSING BO ND )$.2 SIo$he."#
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In the Matter of
)
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LONG ISLAND LIGHTING COMPANY
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)
Docket No. [5,0--)22dOId (Shoreham Nuclear Power Station,
)
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Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of the "SUFFOLK COUNTY MOTION TO STRIKE PORTIONS OF LILCO PREFILED TESTIMONY ON SC CONTENTION 16 -- ANTICIPATED TRANSIENTS WITHOUT SCRAM" have been served on the following by U.S. Mail, first class (except as otherwise indicated), this 27th day of July, 1982.
Lawrence Brenner, Esq.
(*)
Ralph Shapiro, Esq.
Administrative Judge Cammer and Shapiro' Atomic Safety and Licensing Board 9 East 40th Street 1 U.S.
Nuclear Regulatory Commission New York, New York Washington, D.C.
20555 10016 Howard L.
Blau, Esq.
Dr. James L.
Carpenter
(*)
217 Newbridge~ Road Administrative Judge Hicksville, New York 11801 l
Atomic Safety and Licensing Board l
U.S. Nuclear Regulatory Commission W.
Taylor Reveley III, Esq. (*)
Washington, D.C.
20555 Hunton & Williams P.O. Box 1535 Dr. Peter A.
Morris
(*)
Richmond, Virginia ~23212 Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mr. Jay Dunkleberger I
Washington, D. C.-
20555 New York State Energy Office Agency Building 2 Edward M. Barrett, Esq.
Empire State Plaza General Counsel Albany, New York 12223 l
Long Island Lighting Company l
250 Old Country Road Stephen B.
Latham, Esq.
Mineola, New York 11501.,
Twomey, Latham & Shea j
Attorneys at Law l
Mr. Brian McCaffrey P.O.
Box 398 l
Long Island Lighting Company 33 West Second Street 175 East Old Country Road Riverhead, New York 11901 Hicksville, New York 11801 L
"g o
.-a Marc W.
Goldsmith Mr. Jeff Smith Energy Research Group, Inc.
Shoreham Nuclear Power Station 400-l'Totten Pond Road P.O. Box 618 Waltham, Massachusetts ~ 02154
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North Country Road Wading River, New York 11792 Joel Blau, Esq.
New York Public Service Commission MHB Technical Associates The Governor Nelson A.
Rockefeller 1723 Hamilton Avenue Building Suite K Empire State Plaza San Jose, California 95125 Albany, New York 12223 Hon. Peter Cohalan David H.
Gilmartin, Esq.
Suffolk County Executive Suffolk County Attorney-County Executive / Legislative County Executive / Legislative Bldgr Building Veterans Memorial Highway Veterans Memorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Atomic Safety and Licensing" Ezra I.
Bialik, Esq.
Board Panel Assistant Attorney General U.S. Nuclear Regulat'ory Commission Environmental Protection Bureau Washington, D.C.
20555 New York State Department of Law Docketing and Service Section 2 World Trade Center office of the Secretary New York, New York 10047 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Bernard M.
Bordenick, Esq.
(*)
U.S. Nuclear Regulatory David A.
Repka, Esq.
Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C..
20555 Stuart Diamond Matthew J. Kelly, Esq.
Environment / Energy Writer Staff. Counsel, New York State NEWSDAY
.Public Service Commission Long Island, New York 11747 3 Rockefeller Plaza
. Albany, New York 12223 Cherif Sedky, Esq.
Kirkpatrick, Lockhart, Johnson & Hutchison 1500 Oliver Building Pittsburgh, Penn. 15222 WJ M
Lawrence Coe Lanpher KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W.,
8th Floor Washington, D.C.
20036 July 27, 1982